An ice manufacturer using anhydrous ammonia in the plant’s refrigeration system under went an OSHA PSM inspection in September 2015. OSHA’s inspection found that the plant failed to:
- Document that equipment used in the refrigeration system complied with recognized and generally accepted engineering practices.
- Conduct a pre-startup safety review following modifications to the refrigeration system.
- Implement procedures for controlling an outside contractor’s access to process areas.
- Evaluate an outside contractor’s safety and health programs.
Other hazards identified during OSHA’s inspection included:
- Lack of weatherproof covers on circuit breakers in wet locations.
- Spliced and uninsulated power cords.
- An exposed electrical switch.
- Unmarked exits. (OSHA cited the company for similar exit hazards at its NY location in February 2013.)
Here is a breakdown of the citations:
Citation 1 Item 1
Type of Violation: Serious; $7,000
29 CFR 1910.119(d)(3)(ii): The employer did not document that equipment complies with recognized and generally accepted good engineering practices.
(a) Machinery Room – On, or about September 17, 2015, the employer did not document that the door leading from the ice making room into the machinery room, which was not marked with a restricted access sign, complied with recognized and generally accepted good engineering practices (RAGAGEP) such as, but not limited to IIAR 2-2008 Equipment, Design, and Installation of Closed-Circuit Ammonia Mechanical Refrigeration Systems, Section 13 .1.2 Accessibility, Para. 13.1.2.4, which requires access to refrigerating machinery rooms to be restricted to authorized personnel; and for each door to be clearly marked with permanent signs posted at each entrance indicating this restriction.
(b) Machinery Room – On, or about September 17, 2015, the employer did not document that the machinery room doors that were not tight-fitting, in that they were not equipped with seals, complied with recognized and generally accepted good engineering practices (RAGAGEP) such as, but not limited to IIAR 2-2008 Equipment, Design, and Installation of Closed-Circuit Ammonia Mechanical Refrigeration Systems, Section 13. 1.10 Entrances and Exits, Para. 13 .1.10.1 , which requires each refrigeration machinery room to be equipped with a tight-fitting door or doors that open outward and are self-closing if they open into the building.
(c) Machinery Room – On, or about September 17, 2015, the employer did not document that the mechanical ventilation system inlet air obtained from the loading dock area where vehicles with internal combustion engines were operated and carbon monoxide could exist, complied with recognized and generally accepted good engineering practices (RAGAGEP) such as, but not limited to IIAR 2-2008 Equipment, Design, and Installation of Closed-Circuit Ammonia Mechanical Refrigeration Systems, Section 13.3 Ventilation, Para. 13.3.3.2, which requires the ambient inlet air to be clean and uncontaminated.
(d) Machinery Room – On, or about September 17, 2015, the employer did not document that the machinery room emergency ventilation system exhaust fan that discharged horizontally, complied with recognized and generally accepted good engineering practices (RAGAGEP) such as, but not limited to IIAR 2-2008 Equipment, Design, and Installation of Closed-Circuit Ammonia Mechanical Refrigeration Systems, Section 13.3 Ventilation, Para. 13.3.7.1, which requires all exhaust fans to discharge vertically with a minimum discharge velocity of 2500 feet per minute (FPM).
Citation 1 Item 2
Type of Violation: Serious; $7,000
29 CFR 1910.119(h)(2)(i): The employer, when selecting a contractor, did not obtain and evaluate information regarding the contract employer’s safety performance and program:
(a) Covered Process Equipment – On, or about September 24, 2015, the facility failed to evaluate the safety and health programs of mechanical contractor, XXXXXXXX. The mechanical contractor lacked safety programs such as, but not limited to hazard communication and respiratory protection.
Citation 1 Item 3
Type of Violation: Serious; $7,000
29 CFR 1910.119(h)(2)(iv): The employer did not implement safe work practices consistent with paragraph (f)(4) of this section to control the entrance, presence and exit of contract employers and contract employees in the covered process areas.
(a) Process Areas – The employer developed, but failed to implement their safe work practices for controlling outside contractor access to covered process areas within the facility. Employees from XXXXXX (refrigeration contractor) and XXXXXX (engineering firm) accessed covered process areas such as, but not limited to the machinery room, ice making room, and roof during the performance of inspection, maintenance, and repair work on process equipment that contained anhydrous ammonia, without notifying an Arctic Glacier U.S.A., Inc. employee of their presence; or by signing in/out on the visitors log. OSHA documented eight specific instances that occurred between September 11 , 2015 and January 14, 2016.
Citation 1 Item 4
Type of Violation: Serious; $7,000
29 CFR 1910.119(i)(1): The employer did not perform a pre-startup safety review for new facilities and for modified facilities when the modification was significant enough to require a change in the process safety information.
(a) Covered Process On, or about September 24, 2015, a pre-startup safety review was not performed after the stop valve, safety relief valves, and associated relief header vent line piping were upgraded on the recirculator pressure vessel, National Board # 14829 / Serial# 1453656_02; and prior to re-introducing anhydrous ammonia back into the process.
Citation 1 Item 5
Type of Violation: Serious; $7,000
29 CFR 1910.305(c)(4): Snap switches mounted in boxes did not have faceplates installed so as to completely cover the opening and seat against the finished surface:
(a) Packaging Room, Line 6 – On, or about September 11 , 2015, the electrical enclosure housing the on/off snap switch on the Hamer Automated Packaging System, Model # 125-5 I Serial# 15816063, did not have a faceplate cover installed over the opening.
Citation 1 Item 6
Type of Violation: Serious; $3,000
29 CFR 1910.305(j)(2)(iv): A receptacle installed in a wet or damp location was not suitable for the location: (a) Packaging Room, 300# Ice Block Line – On, or about October 5, 2015, the electrical outlet enclosures mounted on each of the-Clinebell Equipment Co. Inc. Carving Block Machines were susceptible to coming into contact with water when electrical equipment such as, but not limited to submersible pumps were plugged into the outlets, because the equipment cord(s) prevented the covers from closing and creating a seal to prevent water intrusion.
Citation 1 Item 7
Type of Violation: Serious; $7,000
29 CFR 1910.305(g)(2)(ii): Hard-service cord and junior hard-service cord No. 14 and larger were repaired by splicing, which did not retain the insulation, outer sheath properties, and usage characteristics of the cord being spliced.
(a) Packaging Room – On, or about September 11 , 2015, the power cord on the Hamer Automated Packaging System’s wire tie drive motor, Model # 125-5 I Serial # 15816063, was spliced together using flexible cords and wire nuts, which did not retain the insulation and outer sheath properties of the cord.
(b) Packaging Room On or about September 11, 2015, the power cord on the Hamer Automated Packaging System’s ice bag conveyor belt drive motor, Model # 125-5 I Serial # 15816063, was spliced together using flexible cords and wire nuts, which did not retain the insulation and outer sheath properties of the cord.
Citation 2 Item 1
Type of Violation: Repeat; $22,000
29 CFR 1910.37(b)(2): Each exit was not clearly visible and marked by a sign reading “Exit”:
(a) Ice Making Room – On, or about September 17, 2015, the exit route door leading outside was not marked with an “Exit” sign.
(b) Ice Making Room On, or about September 17, 2015, the exit route door leading to the loading dock area was not marked with an “Exit” sign. Company was previously cited for a violation of this occupational safety and health standard 29 CFR 1910.37(b)(2), which was contained in OSHA inspection number 623559, citation number 1, item number 5 and was affirmed as a final order on September 24, 2013, with respect to a workplace located in Mamaroneck, NY.
CLICK HERE for a copy of the citations.